The FCC’s revised foreign sponsorship identification rules went into effect on June 10, 2025. However, the FCC has deferred the compliance deadline for the revised rules until December 8, 2025, giving broadcasters an additional six months to come into compliance.
As we discussed previously, the revised rules require broadcast licensees to determine if a foreign sponsorship identification is needed, and to disclose the identity of any foreign governmental entity that leases time on a radio or television station. Broadcasters have two options for determining if a disclosure is needed: a certification option and a screenshot option. With either approach, broadcasters are required to retain certifications and/or screenshots for the longer of their license terms or one year.
The FCC enacted the “two options” approach after a federal court struck down the FCC’s previous rule that had required broadcasters to conduct database searches to determine if a program lessee was a foreign governmental entity.
For more information about the foreign sponsorship identification rules, contact an attorney in our Media practice group.
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